4203_ChampionSiteChronology_2009

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Marietta, Georgia 30062
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Chronology of Low Ground Landfill
International Paper Company — Roanoke Rapids, North Carolina
The Flyash Disposal Area, also called the Low Ground Landfill, is located southeast of
the KapStone Kraft Paper Corporation (KapStone) facility along the Roanoke River in
Roanoke Rapids, North Carolina. The total size of the permitted closed landfill is 23.5
acres. During it's operation under Permit No. 42-03, the following waste material and
composition were disposed: flyash, sawdust and bark, wood pallets, concrete, asbestos
and naturally occurring radioactive material (NORM).
The following paragraphs are a chronological summary of the information that was
available in PREMO Group Inc. files.
• On May 6, 1981, The State of North Carolina Department of Human Resources
issued Solid Waste Permit No. 42-03 to Champion International Corporation
(Champion) to operate a sanitary landfill located on the plant property in Halifax
County, North Carolina.
• On May 7, 1981, the Erosion Control Plan for the Flyash Disposal Site was approved
with conditions by the North Carolina Department of Natural Resources &
Community Development.
• On June 9, 1981, the landfill site was documented to be in very good condition by
the NC Department of Human Resources Division of Health Services.
• On July 31, 1984, the Division of Health Services approved the disposal of asbestos
waste in the permitted landfill.
• On August 14, 1990, representatives from the North Carolina Solid Waste Section,
Champion International Corporation and Sirrine Environmental Consultants (Sirrine)
met to discuss the conditions of the flyash disposal area and a proposed operating
and closure plan. The meeting was documented in a memorandum dated August
18, 1990, by Ms. Francine Durso, P.E., of Sirrine.
• The original Operational and Closure Plan for the Flyash Disposal Area was dated
October, 1990 and revised April, 1991 (Sirrine Environmental Consultants, Inc.).
• On March 18, 1991, the Roanoke Rapids Sanitary District submitted an executed
copy of an agreement whereby the Roanoke Rapids Sanitary District agrees that the
flyash which encroaches on the District's sewer easement does not pose a
restriction to the District's future use for operation, maintenance, or replacement of
water and/or sewer systems.

Low Ground Landfill — Roanoke Rapids, NC
Chronology
Page 2 of 3
November 19, 2009
In accordance with revised solid waste rules adopted in 1995, "The Operational and
Closure Plan for Flyash Disposal Area Update" was submitted in August 1997 (Rust
Environment & Infrastructure). Items that were addressed in this update included:
final grading, location of asbestos and NORM Waste Materials, final cover material,
erosion control plan, vegetative cover, installation of an additional monitoring well,
maintenance and land use after closure and closure conditions.
• On June 27, 1996, International Paper notified NC Department of Environment,
Health and Natural Resources, Division of Solid Waste of their intent to stop waste
deposits on December 31, 1997.
• On August 20, 1996, representatives from NC Solid Waste Section, Champion and
Rust Environmental & Infrastructure met on site to review the requirements to close
the flyash disposal site. The discussions and details of this meeting were
summarized in a Trip Report, dated August 22, 1996, by Champion.
• In the letter dated August 22, 1996, the State of North Carolina Division of Waste
Management, Solid Waste Section had determined that the Permitted Landfill was in
compliance with Rule .0503(2)(d)(ii) of the NC Solid Waste Management Rules
codified at 15A NCAC 13B and that Champion had satisfied the criteria of this rule
by closing the landfill before January 1, 1998.
• In the letter dated September 18, 1996, NCDEHNR requested the installation of an
additional monitoring well on the southeast margin of the landfill.
• On November 4, 1997, the NC Division of Water Quality (DWQ) approved the
Erosion and Sedimentation Control Plan.
• On September 9. 1998, Champion submitted to NC DEM Groundwater Section
analytical results on the flyash.
• The July 28, 1999 letter addressed to Mr. James Coffey of the NC DEHNR Division
of Solid Waste served as the notice of completed Closure of Champion Flyash Site,
Permit 42-03. This cover letter was attached to the Certification Report prepared by
Earth Tech (formerly Rust Engineering and Infrastructure).
• In their February 15, 1999 letter, NCDENR requested a copy of a well location map
and copies of the well construction records and soil boring logs for each of the two
newly installed monitoring wells at the flyash landfill.
• In the April 27, 2006 email correspondence with Mr. Ed Mussler of NCDENR, Mary
Lee Ransmeier, Environmental Manager for IP requested a letter of final closure
from NCDENR indicating use restrictions and or continued use. Documentation of a
follow-up telephone conversation with Mr. Coffee of NCDENR, on April 27, 2006
stated that the state rarely sends acceptance letters unless a change is
wanted...."the company should assume that the plan was accepted and continue to
follow as written/submitted".
• Ownership of the Roanoke Rapids mill changed from International Paper to
Kapstone Kraft Paper Corporation in January, 2007.
In an email dated, September 25, 2008, Mr. Ken Pickle of the NC DWQ Stormwater
Permitting Unit agreed that the landfill was closed out and was not subject to
NPDES stormwater permitting and no official permit action for IP is required.
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Low Ground Landfill — Roanoke Rapids, NC Page 3 of 3
Chronology November 19, 2009
Notes:
1. The landfill was closed in 1998 according to the 1997 Operational and
Closure Plan under which semi-annual groundwater monitoring is required.
Closure consisted of the placement of a two -foot cover consisting of flyash
and dewatered primary clarifier sludge and the establishment of vegetation
over the cover to prevent erosion.
2. A perimeter berm was constructed on top of the landfill and six drop inlets
were constructed. The drop inlets consist of a concrete apron and curb at the
toe of the berm and a steel grate, which discharge to a rip -rap apron.
3. The landfill is inspected for erosion, settling, or subsidence during mowing
and groundwater monitoring events. Areas of erosion, settling, or subsidence
are repaired to restore final grade and to re-establish vegetation. Seeding
and fertilization are performed on an as needed basis. Due to the maturity of
the established vegetation on the cover, no repairs, seeding, or fertilization
are anticipated.
4. The chain -link fence along the southern side of the landfill is inspected for
integrity during groundwater sampling events.
5. Five (5) existing groundwater monitoring wells (LG1, LG3, LG5, LG6, LG7)
are sampled and analyzed on a semi-annual basis in May and November.
Groundwater sampling is conducted using standard low -flow methodology.
Field parameters are collected during low -flow purging include conductivity,
pH, temperature, and turbidity. Samples are collected for laboratory analysis
of: Arsenic, Barium, Cadmium, Chromium, Copper, Iron, Lead, Manganese,
Mercury, Selenium, Silver, Zinc, Biochemical Oxygen Demand, Chloride,
Chemical Oxygen Demand, Total Organic Carbon, Total Dissolved Solids,
pH, Nitrate, Sulfate, Fluoride, and Total Organic Halides. Samples for metals
analysis are collected for total metals analysis with no field filtration.
6. All sampling and analytical methodologies will be consistent with the
requirements of NCDNER Division of Solid Waste regulations and guidance
(NCDENR, February 23, 2007). Analytical lab data and field data are
submitted in Electronic Data Deliverable (EDD) format as required under
NCDENR Solid Waste Section guidance (NCDENR, February 23, 2007) and
in .xIs format per requested Solid Waste Section templates.
7. Analytical results are compared to current Solid Waste Section Limits (SWSL)
and the North Carolina 2L standards (2L). Environmental Monitoring Report
Forms (EMRF) are included in each electronic report sealed by a geologist or
engineer licensed in North Carolina if hydrogeologic or geologic calculations,
maps, or interpretations are included.
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